BizJet International Sales and Support, Inc.

Member of the Lufthansa Technik Group

3515 N. Sheridan Rd, Tulsa, OK 74115, USA

1

July 24, 2015

U.S. Department of Transportation

Federal Aviation Administration

Fort Worth Aircraft Certification Office, ASW-140

2601 Meacham Boulevard

Fort Worth, TX 76137-4298

Subject: Petition for Exemption from 14 CFR 25.813(e) to Allow a Pocket Door to be Installed on 

Airbus A318-112 Series aircraft.

The purpose of this letter is to petition for exemption from Title 14 Code of Federal

Regulations (CFR) 25.813(e) to allow a pocket door to be installed on Airbus A318-112 series aircraft. 

Relief is requested from 14 CFR 25.813(e) at amendment 25-88 in accordance with Airbus A318 Type 

Certificate Data Sheet A28NME as provided for in 14 CFR 11.61(b).

BizJet International Sales and Support, Inc. (BJI) respectfully requests that the public comment period be 

kept as short as permissible, given that this petition is based on previous exemptions similar in nature that 

have been granted to other manufacturers and aircraft modifiers.

Contact Information of Petitioner:

BizJet International Sales and Support, Inc.

Attn: Francesca Walker, Certification Manager

Francesca.Walker@bizjet.com

3515 North Sheridan Road

Tulsa, OK 74115

(918) 281-7478

Section of the CFRs that are affected:

14 CFR 25.813(e), Amendment 25-88: "No door may be installed in any partition between passenger 

compartments.''

Extent of Relief Being Sought and Reasoning:

Title 14 of the Code of Federal Regulations (14 CFR) Parts 25 govern type design certification 

requirements for transport category airplanes. The primary intent of the CFR, as applied to transport 

aircraft, relates to commercial or common-carriage applications. These regulations are to ensure that 

aircraft manufacturers provide the appropriate design features to meet the standards necessary to protect 

the traveling public. These requirements define the normal public interest and safety level and provide 

regulatory guidelines to meet them. When an individual 
BizJet International Sales and Support, Inc.

Member of the Lufthansa Technik Group

3515 N. Sheridan Rd, Tulsa, OK 74115, USA

2

aircraft is to be used in private service (e.g., not for hire or common carriage), it is appropriate to take into 

consideration the specific needs of a different population of more experienced passengers and the 

operations specific to those passengers.

Historically, the authorities have made adjustments to specific requirements based upon specific design 

and operational factors. As stated above, numerous exemptions and other regulatory changes have been 

granted to meet specific aircraft designs and applications. In like manner, BJI proposes to use mitigating 

design requirements and operational limitations to justify similar exemptions to aircraft modified for VIP, 

not-for-hire, or common-carriage service.

The pocket door that is provided requires that BJI receive the requested exemption from 14 CFR 

25.813(e), Amendment 25-88 for the installation when the aircraft is operated under 14 CFR Part 91 or 

125 operating rules. This regulation requires that "no door may be installed in any partition between 

passenger compartments." This exemption would not apply when the aircraft is operated under 14CFR 

Part 135 operating rules, and the door must be locked in the open position by a maintenance action. 

The interior configuration installed results in a very small passenger population compared to for-hire or 

common-carriage standards. These passengers are typically very experienced travelers. For this reason, 

the crews and passengers who fly on this aircraft have a substantially higher familiarity with the aircraft 

and its systems than those envisioned by the writers of the original regulations.

The exemptions proposed herein are justified based upon the following facts:

 This aircraft carries a significantly fewer number of passengers compared to the originally typeapproved passenger load.

 Special Federal Aviation Regulation (SFAR) 109, Special Requirements for Private Use 

Transport Category Aircraft, was issued in 2009 to address these issues, among others. This 

SFAR is limited to aircraft with passenger counts of 60 or less. These requested exemptions will 

apply the same or similar requirements to an aircraft.

 Similar exemptions have been routinely granted for VIP transport category aircraft for many 

years. For example: Exemptions 10339, 6820/6820A, 6881, 7317/7317A, 7609, and 8765, as well 

as others, have been either fully or partially granted by FAA.

 These exemptions have been granted to both domestic and foreign applicants, and applied equally 

to both domestically-produced aircraft and foreign-produced aircraft.

 The Petitioner proposes mitigating requirements and conditions that establish acceptable levels of 

safety for the occupants consistent with previous grants.

Description of the Issue and Historical Supporting Information:

Following air accidents in the 1960's, the Federal Aviation Administration (FAA) amended 14 CFR Part 

25, in Amendment 25-1, to prohibit installation of doors "between passenger compartments." At the time 

of the amendment, it was common practice to divide first class and tourist class cabins with a solid door. 

It was determined in the course of accident investigations that this door could be detrimental in 

evacuation of passengers. The resulting regulatory change was geared specifically at preventing this 

occurrence.

Amendment 25-116 to Part 25 prohibits interior doors between the exit and the passenger compartment. 

In addition, §121.301(f)(6), Amendment 121-306, prohibits these doors in airplanes manufactured after 
BizJet International Sales and Support, Inc.

Member of the Lufthansa Technik Group

3515 N. Sheridan Rd, Tulsa, OK 74115, USA

3

November 27, 2006, operated under 14 CFR Part 121. Amendments 25-116 and 121-306, titled 

"Miscellaneous Cabin Safety Changes", were published in the Federal Register on October 27, 2004. For 

many years, the FAA has granted exemptions for the installation of doors between passenger 

compartments for non-commercially operated transport category airplanes. These exemptions include 

limitations that the airplanes are not operated for hire or offered for common carriage. This limitation 

does not preclude the operator from receiving remuneration to the extent consistent with 14 CFR Parts 

125 and 91, subpart F. Also, these exemptions included the following conditions:

1. Each door between passenger compartments must be frangible.

2. Doors must be in the open position during taxi, takeoff and landing. 

3. Appropriate procedures must be established to signal the flight crew that a door between 

passenger compartments is closed and to prohibit takeoff or landing when a door between 

passenger compartments is not in the proper position.

4. Doors between passenger compartments must have dual means to retain them in the open 

position, each of which means must be capable of withstanding the inertia loads specified in § 

25.561.

Additionally, on May 8, 2009, the FAA amended the airworthiness standards for transport category 

airplanes by adding new cabin interior criteria for operators of private use, not for hire, not for common 

carriage airplanes. SFAR 109 provides alternative criteria for transport category airplanes that are 

operated for private use while continuing to provide an acceptable level of safety for those operations. 

Specifically, item 10 permits the following requirements in lieu of the requirement of § 25.813(e).

(a) Each door between any passenger seat, occupiable for taxi, takeoff, and landing, and any 

emergency exit must have a means to signal to the flightcrew, at the flightdeck, that the 

door is in the open position for taxi, takeoff and landing.

(b) Appropriate procedures/limitations must be established to ensure that any such door is in 

the open configuration for takeoff and landing.

(c) Each door between any passenger seat and any exit must have dual means to retain it in 

the open position, each of which is capable of reaching the inertia loads specified in Sec. 

25.561.

(d) Doors installed across a longitudinal aisle must translate laterally to open and close, e.g., 

pocket doors.

(e) Each door between any passenger seat and any exit must be frangible in either direction.

(f) Each door between any passenger seat and any exit must be operable from either side, 

and if a locking mechanism is installed, it must be capable of being unlocked from either 

side without the use of special tools.

Discussion:

This discussion covers doors that separate passenger compartments from other areas throughout the 

aircraft. This discussion does not include doors that separate e.g. lavatories or bathrooms from passenger 

compartments and these doors do not apply to this exemption request.
BizJet International Sales and Support, Inc.

Member of the Lufthansa Technik Group

3515 N. Sheridan Rd, Tulsa, OK 74115, USA

4

The interior door of the current layout for the proposed VIP interior separates a passenger compartment 

from other areas (e.g. exit area). There is only one interior door that directly separate two passenger 

compartments. This interior door is installed in between the aft hallway and the private office.

The door between passenger compartments and other areas (e.g. emergency exits) will have the following 

design features:

 The door will be operated manually.

 The door needs to be latched in the open position and will have dual latches (each of which is 

able to withstand the forces defined § 25.561(b)) to secure the door in the open position and to 

prevent inadvertent closing.

 The doors will be frangible to allow egress in the event that they should become stuck.

 The door will provide vent areas to allow free airflow in the event of a rapid decompression.

 In case a locking mechanism is installed, these doors will provide features to unlock the door 

from either side without the use of a special tool.

 Cockpit indication of the door position for taxi, take-off and landing.

 Cabin crew indication of each individual door position to identify which door/doors is/are not in 

the correct position for taxi, take-off and landing.

Safety Considerations:

The risk for occupants due to the use of doors between passenger compartments should be considered 

acceptable due to the features mentioned above and for the following reasons:

 The airplane will nominally be operated under 14 CFR Parts 91 and 125, or foreign equivalent, 

and will not be operated for hire or offered for common carriage.

 When operated under 14 CFR Part 135, the Airplane Flight Manual Supplement (AFMS) will 

require a maintenance procedure to permanently disable the door in the open position. 

 A revised AFMS will provide procedures and limitations to ensure that the doors are in the proper 

position for taxi, take-off and landing.

Requested Relief:

BJI proposes to meet the requirements as stated similarly in SFAR 109 and various Exemptions when 

operated under 14 CFR Parts 91 or 125 as:

 In lieu of the requirements of § 25.813(e), interior doors may be installed between passenger seats 

and exits, provided the following requirements are met:

- Each door between any passenger seat, occupiable for taxi, takeoff, and landing, and any 

emergency exit must have a means to signal to the flight-crew, at the flight-deck, that the 

door is in the open position for taxi, takeoff and landing.

- Appropriate procedures/limitations must be established in the AFM to ensure that any 

such door is in the open configuration for taxi, take-off and landing.

- Each door between any passenger seat and any exit must have dual means to retain it in 

the open position, each of which is capable of reacting the inertia loads specified in § 

25.561(b).

- Each door between any passenger seat and any exit must be frangible in either direction. 

A frangibility test will be performed on each type of interior compartment door 

installation in the aircraft using a 5th percentile female subject.
BizJet International Sales and Support, Inc.

Member of the Lufthansa Technik Group

3515 N. Sheridan Rd, Tulsa, OK 74115, USA

5

- Each door between any passenger seat and any exit must be operable from either side, 

and if a locking mechanism is installed, it must be capable of being unlocked from either 

side without the use of special tool.

 When the aircraft is equipped with interior doors under this Exemption:

- The AFM must include appropriate limitation(s) to require a preflight passenger briefing 

describing the appropriate functions to be performed by the passengers and the relevant 

features of the airplane to ensure the safety of the passengers and crew.

- The AFM must include instructions to permanently lock the door in the open position by 

a maintenance action prior to any operations that are common carriage or for hire.

Statement of Public Interest:

As in the cases of numerous already established Exemptions, granting this petition for exemption would 

be clearly in the public interest of the people of the United States of

America for the following reasons:

 Given the proliferation of VIP configured Transport Category Airplanes, and anticipated in 

the near future, approval of these exemptions will enable the United States modifiers of 

Transport Category Airplanes to effectively compete in this expanding market.

 Additional sales of components manufactured in the United States even for VIP interiors 

installed outside the United States will serve to increase supplying/supporting company’s 

profitability.

 Stability and improved financial performance of these United States companies gives greater 

job stability to the workers employed by the companies, causing a stabilizing influence to the 

greater United States economy, due to the consumer pending activities associated with stable 

workers.

 Improved financial performance of United States owned and operated corporations, and 

increased workforce stability translates into continued and improved local, state, and federal 

tax revenues which in turn add to the stability of the total United States economy.

 Improved financial performance allows United States corporations to continue to invest in 

Research and Development, allowing the United States to maintain or improve its 

competitive position in the world economy.

Per 14 CFR 11.81 (h), BJI requests that the privileges of this exemption be extended outside the United 

States. This extension of privileges is necessary for operations based within foreign countries having 

bilateral agreements with the United States accepting FAA 14 CFR Part 25 as their airworthiness 

standards for transport category aircraft. Similar interior modifications with interior doors are intended for 

the global market place.

Request for Wavier of Publication:

BJI requests that the public comment period be waived since this request is identical in all material 

aspects to several previously-granted exemptions for which no comments were received, and if the 

petition for exemption were granted, would not set a precedent.

BJI appreciates your consideration of this petition. If you have any questions, please do

not hesitate to call.
BizJet International Sales and Support, Inc.

Member of the Lufthansa Technik Group

3515 N. Sheridan Rd, Tulsa, OK 74115, USA

6

Sincerely,

Francesca Walker

Certification Manager

BizJet International Sales and Support, Inc.

3515 North Sheridan Road

Tulsa, OK 74115

(918)281-7478